Award administration at the University of West Florida involves many activities regarding the management of sponsored funds, compliance with federal regulations and adherence to UWF policies and procedures.
Conflict of Interest/Outside Activity
- Policy - Conflicts of Interest (AC-11.02 - 05/13)
- Form - Report of Outside Activity/Conflict of Interest (10/24/13) (PDF)
- Form - Use of University Resources in Outside Activity (7/29/10) (PDF)
Cost Transfer Explanation and Justification Form (Excel)
Internal Routing Form (IRF) (Word)
Request for Sponsored Research Purchasing Exemption (Excel)
Salary Calculator (Excel)
Temporary Authorization for Advanced OR Post-Award Account Expenditures (Excel)
What to do next
Acceptance of an Award
An award to the university from a sponsoring agency is a legal document which obligates the university. An award may be simply in the form of a letter issued by an authorized agent of the sponsor or it may consist of a detailed, lengthy contractual document. RSP is the office authorized to accept and execute awards on behalf of UWF. RSP will consult with the PI if the award differs from the submitted proposal, so that the award may be accepted, modified, or rejected. No charges may be incurred against a sponsored project until such time as RSP has received and processed an original award notification from the sponsor, and a grant/fund number has been issued by RSP to the Principal Investigator (PI).
Only certain administrators have been authorized to offer proposals, issue certifications and assurances for a proposal for the university or accept a contract or award document. This designation is by Presidential Signature Authorization Policy P-04.01-11/09. All documents must be approved for signature by the university's Office of the General Counsel. No other signature is considered to be legally binding upon the university and is subject to withdrawal if received after-the-fact.
UWF has established an institutional approval process for projects requiring expenditures prior to the receipt of the award document or the final execution of a contract when it is highly probable that such approval is anticipated. In order to request advance authorization, the PI should have confirmation of the sponsor’s intent to fund and a date approved for beginning period of performance. OMB Circular A-21 allows federal agencies and funds authorized to approve expenditures up to 90 days prior to the beginning of the period of performance for pre-award start-up costs with the agency’s approval. Under this system, approval must be authorized by the responsible officials (PI, director/chair, dean/vice president, and provost). For this purpose, a Temporary Authorization for Advanced OR Post-Award Account Expenditures (Excel) request should be submitted to RSP. Submission of this form commits the PI, department, and college/division to reimburse university accounts in the event that the expected sponsor authorization is not forthcoming or advanced expenditures are disallowed. RSP will recommend an action to approve or disapprove such a commitment only after the proper authority at the granting agency has assured us of their intent to provide such funding with an anticipated effective date.
In some cases, an award may be issued by the agency after a series of negotiations which may involve revisions to the scope of the project and/or to the proposed budget. RSP is the authorized agent for conducting and approving such revisions, but no changes to a project or a budget are authorized without the express consent of the PIs. Faculty researchers are reminded that the acceptance of a revised scope of work or budget is a judgment that only they can make; it is not a judgment or condition that may be unilaterally imposed by the granting agency. If the agency requires the submission of a revised work plan or budget, this must be prepared by the PI and submitted to RSP for institutional endorsement and for forwarding to the agency. Upon receipt of an official award by RSP, the PI will receive information pertinent to the award, budget set up and grant/fund number assignment.
UWF has delegated approval to execute any documents which obligate the university to performance or compliance to the University Office of the General Counsel via RSP. Awards, contracts, purchase orders or cooperative agreements are first reviewed by RSP Grants Specialists and prepared for review. Negotiations on modifications are coordinated with the PI prior to final acceptance. Documents approved by the OGC for signature are returned to the RSP Grants Specialist and then executed by authorized University signatory officers as acceptance.
Authorized officers who may approve or execute such agreements on behalf of the university are the Provost and/or designees such as the Associate Vice President for Research. Signatures by any other individuals not approved in the University Signature Authorization Policy P-04.01-11/09 are not considered binding upon the institution. Signatures are implemented under the Policy - Signature Policies for Academic Affairs (PDF).
Procedures for Establishing a Grant/Fund
Once an award is accepted, the RSP Grants Specialist will complete entry of required information in Banner Proposal Record, assign a grant/fund number and send the information to establish a grant/fund with budget in Banner Grant to a Grants & Contract Business Manager. Once activated, expenditures are authorized through regular university procedures. A review session with the PI and any support personnel on management of grant activities is scheduled if it is a new PI or if there are special circumstances in the grant award.
Subcontracting & Subrecipient Agreements
This section provides guidance to the university community regarding subrecipient contracting and monitoring to comply with OMB Circular A-133 (PDF).
Upon completion of the contracting process, award/contract from UWF to subrecipient is transferred to the Grants & Contracts Business Manager for functions related to establishing encumbrances, processing invoices, and monitoring required financial reporting.
Throughout Period of Performance
- PIs monitor completion of deliverables, receipt of invoices, approval of payments, and technical performance of all subrecipients.
- PIs notify RSP of need to amend contract documents or to withhold or modify payment of invoices.
- RSP annually reviews applicable OMB Circular A-133 audits.
At Close Out/Termination
RSP assists PIs in requesting any required reports such as invention disclosure, technical reports to incorporate in UWF reports to sponsor agency.
RSP assists PIs in compiling final financial-related reports such as financial expenditure reports, inventory/property reports, and supporting documentation.
PIs have primary responsibility for monitoring subrecipients to ensure compliance with federal regulations and both prime and subrecipient award terms and conditions.
Departmental business managers have responsibility for assisting PIs in discharging their monitoring responsibilities, for reviewing invoices from subrecipients and questioning expenditures if necessary, and for maintaining documentation of monitoring efforts.
RSP has responsibility for ensuring that the university's subrecipient monitoring procedures are compliant with federal and other applicable regulations and are consistent with sound business practices. RSP will provide further training, monitoring and guidance in interpreting applicable regulations and subrecipient award terms and conditions, and in interpreting and executing these guidelines. Additionally, RSP will conduct web site reviews of any subrecipient published OMB Circular A-133 audits to ensure they are conducted and request copies whenever electronic version are not available as indicated in the contract document through the Federal Audit Clearinghouse web site.
In order to meet requirements for OMB Circular A-133 compliance, the university must meet the requirements regarding subrecipients’ performance and compliance under any prime awards or contracts for which it is the fiscal agent of record. To accomplish this requirement, the operating procedures above have been developed to provide an overview of the requirements, work flow, and responsibilities. RSP assists and collaborates with the PI(s) to perform contracting and financial monitoring. The PI is the primary responsible party for ensuring that sponsored research funds (including subrecipient payments and deliverables) are used as awarded from the sponsor and that costs incurred are “allowable, reasonable, and allocable” and that required reporting is accomplished as outlined in the prime award document.
For assistance, PIs are urged to contact the department’s business manager, chair/director, or RSP staff for specific requests or assistance.
Required Special Approvals
Use of Human Participants
The Institutional Review Board (IRB) for Human Research Participant Protection was established to ensure the ethical conduct of research involving human participants. It is the responsibility of the IRB to assure the university that human participants used in research or educational programs are not at undue risk and that the participants are informed of any risks.
The IRB is a committee of appointed volunteers (both university and non-university representatives) who review and approve the use of human participants in research projects. The IRB meets on a regular basis. IRB meetings are open to investigators and the public.
When the review has been completed, the IRB will notify the researcher and also notify the sponsor, if required. The university will not release funds for a project involving human participants that does not have IRB approval. Further, some federal agencies require assurance that a project has IRB approval before an application will even be reviewed for funding.
Use of Animals
The Institutional Animal Care and Use Committee (IACUC) oversees UWF’s use of animals. UWF embraces the principles set forth in the Public Health Service Policy on Humane Care and Use of Laboratory Animals (PDF) and the Guide to Humane Care and Use of Laboratory Animals (National Research Council).
Use of Biohazards and Recombinant DNA
UWF's policy and guidelines on the use of biohazards and their disposal can be found on the UWF Environmental Health and Safety web site or call 850-474-2525.
Use of Radioactive Materials and Radiation-Producing Devices
UWF's policy and guidelines on the use of radioactive materials and radiation-producing devices can be found on the UWF Environmental Health and Safety web site or call 850-474-2525.
Classified Access and Export Controlled Information
Projects which involve classified information (security clearance access) or which deal with information, materials, and activities which may be subject to export control regulations must follow specific guidelines. See Export Control for more information.
Financial Conflict of Interest
The university's faculty is made up of highly trained professionals, many of them of national and international reputation, representing a substantial reservoir of human resources. Services of this group are available to the various sectors of society for the mutual benefit of industry, government, the academic community and society at large. Outside employment and activities are encouraged, provided they do not detract from the full and competent performance of a faculty member's duties. In light of this, faculty whose activities are paid from grants or contracts should be aware of potential conflict of interest situations.
The university's policy on conflict of interest is found in UWF policy HR-15.00 Employee Code of Ethics (PDF) and applicable collective bargaining agreements. In addition, Academic Affairs has information and forms pertaining to faculty Conflict of Interest and Outside Employment Policy on their web page Policies, Procedures & Resources.
Federal regulations require that the university manage, reduce, or eliminate any actual or potential conflicts of interest that may be presented by the compensated outside activities and other financial interests of persons involved in sponsored research projects funded by federal agencies. In addition, granting agencies may have their own conflict of interest requirements which must be adhered to. These federal regulations are designed to prevent bias in the design, conduct, or reporting of research projects.
Any investigator submitting a proposal to the Department of Health and Human Services (DHHS) or National Science Foundation (NSF) must report any "Significant Financial Interest" that would reasonably appear to be affected by the proposed or funded research activities, including interests maintained in entities that would be so affected. An investigator is defined as the Principal Investigator (PI), co-PI, or any other employee responsible for the design, conduct, or reporting the proposed or funded research or educational activities. For the purpose of determining a Significant Financial Interest, an investigator also includes an employee's spouse and dependent children.
A "Significant Financial Interest" refers to salary or other payments for services, such as consulting fees and honoraria; equity interests, such as stocks and stock options; and intellectual property rights, such as patents, copyrights, and royalties. A Significant Financial Interest does not refer to salary or other remuneration from the university; income derived from seminars, lectures or teaching engagements sponsored by public or nonprofit entities; income derived from service on advisory committees or review panels for public or nonprofit entities; or salary, royalties or other payments that, when aggregated for the investigator and his or her spouse and dependent children, is not expected to exceed $10,000 over a 12 month period, for example. An equity interest that, when aggregated for the investigator, spouse, and dependent children, does not exceed $10,000 and does not represent more than a five-percent ownership interest in any entity is also not considered a Significant Financial Interest.
Significant Financial Interests must be disclosed at the time of the submission of the proposal, but approval of the outside activities and financial interests (with conditions if warranted) need not occur until the project has been funded. The federal regulations also require that the disclosures be made annually during the course of the research, or as new reportable significant financial interests are obtained. The employee must file a new report if a new Significant Financial Interest is obtained consistent with the university's requirement that any material changes to outside activities and financial interests must be reported during the academic year. Review and approval or disapproval of the interests disclosed during the course of a research project must be accomplished prior to initiating the performance.
The department chair/supervisor and the dean/director are responsible for reviewing each disclosure to determine if there is a potential conflict of interest. Under the federal regulations, a conflict will be deemed to exist if a Significant Financial Interest may directly and significantly affect the design, conduct, or reporting of the research. The university, through the department chair/supervisor and dean/director, is required to manage, reduce or eliminate the conflict. Conditions that might be imposed in such cases include public disclosure of the conflict, modification of the research design, or monitoring of the research by independent reviewers. If adequate measures are not feasible, the employee may have to discontinue the compensated activities, divest himself or herself of the financial interest, or discontinue the research. The employee must abide by the conditions under which the research is permitted.
In order to certify compliance with these federal regulations, RSP procedures requires that all investigators and other key personnel on DHHS, NSF and United States Department of Education (U.S. ED) proposals complete and sign a Form - Report of Outside Activity/Conflict of Interest (10/24/13) before the proposal is submitted by RSP. The form should be part of the package submitted for review and approval through the usual departmental, college and unit approval process using the Internal Routing Form (IRF) (Word). It is the PI's responsibility to ensure that Significant Financial Interest Disclosure Form (Word) for all investigators (including co-PIs and other employees responsible for the design, conduct, and reporting of the research) are obtained on a timely basis in order to meet proposal application deadlines.
Regardless of whether or not a conflict exists, the proposal will be submitted to the agency. The form is kept on file in RSP and is not sent to the agency. However, an institutional certification that the university's policy is active and in compliance with the federal regulation will be transmitted to the agency.
Managing Your Grant
Consultant/Contractual Services on Grants
Consultant payments on sponsored projects must represent compensation to individuals who are independent of the university and who render independent services. Consultant payments may not be made by faculty to colleagues where an employer/employee relationship exists. Rather, in these situations, colleagues should be compensated for services via the university personnel/payroll system according to percent effort of committed time; or donate their services as part of their intra-institutional collaboration as a professional courtesy. This expectation is part of the OMB Circulars A-21 and A-133.
On the whole, it is expected that consulting needs can be satisfied from resources within the university community. When outside consulting services are needed for a grant or contract, all of these conditions must be met:
- There must be evidence that the services provided are essential and cannot be provided by persons receiving salary support under the sponsored project.
- There must be evidence that a selection process was employed to secure the most qualified person available.
- There must be evidence that the charge is appropriate considering the qualifications of the consultant, normal charges, and the nature of the services rendered.
- Federal programs limit the amount per hour/day/annum that may be charged as a consultant fee. The rate can be found on U.S. Office of Personnel Management (OPM) Information on Federal Pay and Leave web page under the "Salary Tables." Unless specifically allowed in the agency guidelines, compensation should be limited to the amount for Executive Schedule Level I. The annual cap would be prorated for a daily rate by dividing by 352 and an hourly rate by dividing by 2088. Total annual compensation from all sources should not exceed this salary cap for any individual.
- If an outside consultant is employed, the individual must be established in the UWF Procurement and Contracts system as a vendor. Refer to the guidelines for the requirements for a Consulting and Professional Services contract (see Procurement & Contracts). If the third party is not eligible to be established as a vendor through this method, a subaward or subcontract agreement must be entered into with the individual’s normal employer for services and related costs. Refer to Subcontracting/Subagreement Agreements.
Hiring Research Personnel
Personnel assigned to sponsored projects (funds begin with 16, 18, 21, and 22), like all other personnel, must be appointed and compensated in keeping with federal, state and university personnel rules. Classified staff matters are covered by the Florida Department of Education and HR Policies. Additional faculty policies are covered in the Faculty Handbook (links updated) 1/8/14 or questions may be addressed to the Office of the Provost for Academic Affairs.
RSP Grants Specialists serve as liaisons to UWF Human Resources (HR) to help researchers with questions about the employment of individuals working on sponsored projects. For assistance in these matters, contact your RSP Grants Specialist.
Salaried employees must be classified in accordance with the appropriate university pay plan (Faculty or University Work Force) and are entitled to Fringe Benefit Analysis Chart (insurance, retirement, annual and sick leave benefits) that are funded by the contract or grant through the appropriate fringe benefit percentage rate applicable to the base salary. Employees entirely compensated by grant or contract funded projects should be encouraged to take annual leave during the performance period.
Faculty titles and their use are regulated by the Provost and the respective dean's office and are shown in the Information Navigator report Position Classes (OHR000004) report. Generally, a master's degree is a minimum requirement. The faculty plan has no set pay ranges, but all appointments are subject to the approval of the dean or director and the Provost.
Faculty and UWF staff who are covered by an employment contract (issued at initial employment or upon initial appointment to a grant project) are notified in this document and all subsequent contracts of the time-limited nature of their employment and that no further notice of cessation of employment is required. PIs are provided notice at 90-60-30 day intervals prior to a scheduled end of a grant project and are encouraged to provide notice to all employees on the project as soon as the notices have been received if continued funding has not been assured.
Other Personal Services (OPS) appointments are temporary by nature and are expected to exist no longer than the specific period of appointment. Although no formal notice to these employees is required, Principal Investigators (PIs) are encouraged to provide as much notice prior to a termination of the appointment to the employee as possible.
OPS appointments provide temporary or short-term staffing needs, including faculty, administrative and professional, support staff, and student employment. OPS employees are not eligible for leave/holiday pay. The Patient Protection and Affordable Care Act passed by Congress in March 2010 requires employers throughout the country to offer affordable health insurance coverage to employees who work 30 hours or more on average per week. For the purposes of insurance coverage only, these employees will be considered full-time and will be offered health insurance coverage and other insurance benefits. A small portion of the fringe benefit percentage is assessed to OPS salaries paid to cover the costs for FICA payroll taxes and Workman’s Compensation benefits. This rate is also shown on the Fringe Benefit Analysis Chart (PDF).
OPS appointments may be made for “contract” appointments in which the individual is paid a salary rate to accomplish duties assigned without regard to actual hours worked. This type of appointment is usually made for a professional or faculty level appointment, and the employees will be paid based on the prorated rate for the period of appointment. No time sheets are required, but the PI (or other designated party) must certify each pay period that the work for the FTE appointment has been completed. Unless Payroll is notified, OPS employees in this category and appointed at a biweekly rate remain in full pay status at the assigned FTE during pay periods containing holidays. When change to the biweekly rate for work performed is necessary due to illness, vacation or contracted work not performed during a period when the university is closed, the PI/supervisor is expected to notify Payroll (e-mail is acceptable) on or before time certifications are due for payroll processing.
Fully matriculated graduate students may be appointed as Graduate Assistants or Graduate Research Assistants under grant-funded projects and paid on an hourly basis (see Minimum Pay Rates for Graduate Assistants - PDF). The student’s approved biweekly time sheet serves as the appropriate support documentation of direct costs for grants. Graduate students employed at least 10 hours per week are eligible for matriculation fee waiver (usually partial in-state fees) processed through the appropriate college office. The student must be appointed for the entire length of the term for which the tuition payment is awarded. Whenever possible, investigators are encouraged to include graduate student tuition at the in-state level or the matriculation fee waiver equivalent in their proposed project budgets (see Preparing a Budget).
Student Employment Classification and Pay Plan documents are available at Human Resources Student Employment including information on requisition to fill and requirements for appointment. For assistance, contact your RSP Grants Specialist.
With the permission of the sponsor, students may be paid a “stipend” for work and education during a specific period of time such as an academic term. Stipends are considered compensation in lieu of salary for students and are usually awarded to graduate research assistants who are working directly under a faculty member’s supervision as part of an educational experience. Stipends require a written agreement between the faculty member and the student to outline the expectations of performance and a formal assessment (such as a grade on a directed individual study, thesis credit or approved internship enrollment) completed at the end of the appointment period. The faculty member’s assessment of the student’s performance is expected to include documentation of hours worked toward the completion of the objectives. Stipends must be reported to Student Financial Aid and are calculated as part of the student’s total financial aid package.
Undergraduate students may be employed in any Student Employment Classification other than those specifically designated at the graduate student level. The policies and procedures for these appointments are similar to those for graduate students and details may be found at the Human Resources Student Employment web site.
All personnel working on sponsored projects must be assigned by the department chair or other responsible individual for the period of time and percentage of effort devoted to the sponsored project. This assignment may be compensated by the grant or paid from departmental funds as cost sharing to the project. However, if personnel are appointed to and paid from the sponsored project, “salary savings” occur within the departmental budget and can be released for other purposes within the university, subject to administrative approval. Refer to Preparing a Budget.
The faculty member is expected to be released from the portion (percentage) of the full-time contact hour equivalency. Salary and fringe for this portion is recaptured as a percentage of salary savings. This percentage may vary depending on the individual’s assignment. For example, Professor A has an assignment for a given semester to teach 9.0 contact hours (3 courses) and to provide advising, research and service for the remaining 3.0 contact hours of the required 12.0 contact hours required for a fully-funded FTE position. Professor A is released from one course but is expected to continue previously assigned advising, research and service. The contact hour equivalent of 3.0 contact hours equals a percentage of effort of 25% of the 100% effort assignment. Professor B has the same work assignment but is released from one course and any additional expectation of other departmental research or scholarly activity so the contact hour equivalent released is 4.0 contact hours to equal 33% effort of the 100% effort assignment. Whenever an appointment is made to a sponsored research activity, the faculty member’s work assignment should be made taking into account this consideration or amended if the commitment occurs after the work assignment is accepted.
Both release time and cost sharing of a faculty member’s effort are subject to reporting according to the appropriate contact hours through the Faculty Activity Report System (FARS) and should also be reported as the equivalent percentage of effort on the Personnel Activity Report System (PARS) forms (both forms were replaced by Combined Activity/Effort Reporting System or CAERS as of 5/7/08). The contact hours required generating a 1.0 FTE for a faculty member who has responsibilities related to the FTE generation of E&G funds and the percentage of the individual’s cost effort (prorated 100% effort) should be reconciled at the end of each semester by the submission of the CAERS report. For assistance in determining the appropriate contact hour or cost effort equivalents, contact the college budget managers or your RSP Grants Specialist.
Employment of Relatives on Grants/Contracts
When faculty plan to employ a spouse, child or other close relative on government sponsored projects, the agency must be fully informed about the nature of the relationship and the qualifications which make the services particularly desirable. Furthermore, under UWF policy HR-15.00 Employee Code of Ethics (PDF), no such related person can be employed unless the president or president's designee has determined prior to the appointment that there is no conflict of interest (6C-5.945, Florida Administrative Code). When such appointments are approved, the Principal Investigator (PI) may not approve the appointment, evaluation, approval of compensation such as time sheets for the relative. In these cases, the next level unit supervisor (department chair or institute/center director) is considered the PI designee. The employment of relatives is allowed where there is no conflict of interest, no direct or indirect supervisory responsibility between relatives. Functions of positions must not overlap or require authorization, approval, appraisal, appointment or validation of related parties. "Relatives" or "related" persons are those related to each other as husband, wife, parent, child, brother or sister. Faculty should also refer to the Academic Affairs Policies and Procedures for Conflict of Interest and, if applicable, any regulations or policies of individual sponsors.
Research Integrity Responsibilities
|Ethics & Compliance
Whistleblower Protections under the Recovery Act
Faculty members at UWF are expected to maintain high ethical standards in the conduct and reporting of scientific and scholarly research. The faculty and other research staff have responsibilities for ethical conduct in research not only to the university, but also to the community at large, the academic community, and those private and public institutions to which members of the faculty are bound by affiliation or contract. This responsibility extends to the students or employees directly under the faculty members' supervision. See the following for additional information:
Investigations of Alleged Misconduct in Research
Should alleged incidents of misconduct in research occur, reporting of such possible violations is a widely shared responsibility, and it is the duty of the faculty and administration to respond in a fitting manner to resolve issues arising from such alleged misconduct.
See Faculty Conduct in Research, Section XVI of the Faculty Handbook (links updated) 1/8/14 and the Policy for Responding to Allegations of Misconduct in Research & Scholarly Activity, SR-01.00-12/07.
Allocation of F&A Costs
Since UWF is a state institution, reimbursement for its operational expenses should logically go back to the state, which initially advanced the costs incurred for federally funded projects. However, the Florida Legislature has implemented a far-sighted policy which allows each state university to retain 100% of the recovered F&A cost funds (Florida Statute 1004.22). In addition to funding RSP’s operating costs, these overhead funds are used for a variety of internal support programs and scholarly awards.
F&A Cost Distributions
Each year RSP returns a portion of F&A cost earnings directly to Principal Investigators (PIs) (10%), the department (10%), and the colleges associated with the grant(s) (10%). Funds must be used for the support of research and research-related activities. This return generally occurs in September of each year and is based upon the F&A costs recovered from sponsors in the preceding fiscal year (July 1-June 30).
Some general notes on the distribution process are
- When a grant or project has more than one PI, the distribution is made only to the lead PI. It is then at the discretion of the PI who is primarily responsible for the project management to determine if any portion of this share should be made available to other contributors.
- If a unit (or individual) has changed reporting authority by being assigned to a different department or college, the funds are distributed to the units under which the funds were earned. Future distributions will be modified to show the change in oversight and administration. Please notify us if such change has occurred.
- When a PI has left the university for any reason, the PI's portion of the distribution is made to the appropriate administrative officer (dean or vice-president) responsible for oversight of the unit. It is expected that the Dean/VP is best able to determine the appropriate use of the funds by the department/college. Please notify us if such change has occurred.
Internal Support Programs
RSP supports and provides incentives for research activity at UWF by investing a portion of the university's recovered F&A costs in the following programs:
Cost transfer is a process whereby any expenditure improperly assessed to a sponsored project account is transferred to the correct account. It is the responsibility of the Principal Investigator (PI) to make sure transfers are made promptly after the error is discovered and within 120 days of the original charge unless close-out requirements necessitate a shorter period of time. PIs should contact the Grants & Contracts Business Manager.
Retroactive cost transfers represent one of the most common areas for audit disallowance. Federal regulations (OMB Circular A-21) define improper cost transfers as, "Any costs allocable to a particular research agreement under the standards provided in this circular may not be shifted to other research agreements in order to meet deficiencies caused by overruns or other fund considerations, to avoid restrictions imposed by law or by terms of the research agreement, or for other reasons of inconvenience."
RSP provides notices of upcoming end dates at 90-60-30 day intervals prior to the end of a project along with Information Navigator report RSP000018 Grants Ending Within 30/60/90/120 Days. Upon receipt, it is the responsibility of the Principal Investigator (PI) to notify RSP of any required requests for modification. A no-cost extension occurs when a PI requires more time, but not additional funds, to complete a project. The purpose for the extension should be to benefit the successful completion of research goals.
Many Federal Demonstration Partnership (FDP) grants and Expanded Authority grants are allowed one no-cost extension of up to 12 months without the sponsor's prior approval. However, RSP must provide formal notification to the agency.
If the grant has already had one no-cost extension as an option under Expanded Authority, requests based on additional justification for further no-cost extensions must be submitted to the sponsor through RSP. Most requests should be sent well in advance of the project ending date as some agencies require such requests be made 30 days prior to the project end date; therefore, the internal notification of the anticipated extension is requested no less than 45 days prior to the performance end date. The PI should justify the need for an extended period in scientific terms and should give a projected budget for the extension period. Please note that this is an average requirement. Some agency award terms and conditions require as much as 90 days notice of a request for a no-cost extension. Refer to the specific terms of the award for this requirement.
Advance Budget Authorizations
There are two types of special advances available to investigators through RSP:
Some federal grants that will be awarded under the Federal Demonstration Partnership (FDP) or other Expanded Authority Terms and Conditions allow pre-award spending within the 90 day period immediately preceding the grant’s effective date. Federal grants require the federal agencies' prior approval. To request RSP’s approval for pre-award spending, an investigator must submit a completed Temporary Authorization for Advanced OR Post-Award Account Expenditures to RSP. Pre-award costs are approved only when pre-award spending is necessary for the effective and economical conduct of the project.
Requests for pre-award costs should be made prior to the receipt of the grant. It must include a narrative explaining why the period of performance needs to begin early, a pre-award budget, and the pre-award start date. This request guarantees that the Principal Investigator (PI), department, center or college will cover all expended costs if for any reason the award is not made to the university or pre-authorized expenditures are disallowed. Approval of this form by the PI, department chair/center director, and college dean/VP or other authorized officer commits funds which are being used as the guarantee. The Provost or designee has final approval for all temporary extensions.
Temporary Extension of Unexpended Funds or Additional Release of Funds by Agency
Investigators sometimes experience difficulties in starting or continuing personnel appointments when an award is assured or a funding release is anticipated but the arrival of the award documentation is delayed. RSP normally processes a temporary release for no more that 30 days at a time based on continued supporting documentation of anticipated award.
To request a temporary extension to an account, an Investigator completes the same Temporary Authorization for Advanced OR Post-Award Account Expenditures to RSP. The request must include an anticipated effective start date of the renewal, the amount of unexpended budget to be released or a request for additional funds in excess of the unexpended budget to cover the extension period, and a guarantee statement that the PI, department, center or college will cover all expended funds if for any reason the award renewal or additional funds is not made to the university. The request must be signed by the PI, department chair or center director, and college dean or division vice-president, if college/division funds are being used as the guarantee. The Associate Vice President for Research will have final approval for all temporary extensions.
Investigators should include as an attachment to the request any correspondence they may have from the awarding agency indicating an award is going to be made to the university.
Principal Investigators (PIs) have first line responsibility for managing expenditures within the fiscal regulations and amounts specified by the sponsor. If an over expenditure occurs in a grant account, the PI is responsible for covering the deficit from his or her seed account. In the event that the PI is unable to cover the deficit, responsibility for correction then lies with the department or center and finally with the college or division.
If an error is made resulting in an audit disallowance, corrective action will be determined on a case by case basis by RSP with the help, knowledge, and assistance of the PI.
Any error indicating over-expenditure of funds, whether it be by audit disallowance or otherwise, will be met with current or future returned overhead funds or other unrestricted fund; PIs are notified when refunds occur. Refunds to sponsors as a result of an error or if audit disallowance is found, should be signed by the PI like any other expenditure of funds.
UWF Procurement & Contracts prepares bid specifications, initiates formal quotations, proposals and bids; conducts public bid openings; evaluates bids; and awards and administers all purchase contracts until final completion or termination. Unless otherwise stated, Procurement & Contracts is the only UWF department authorized to commit funds for the acquisition of commodities or services and is the initial point of contact for service contracts and agreements. Requisition procedures can be found on their web site.
Services of a collaborator under a sponsored research project are usually acquired via a Subcontracting/Subrecipient Agreement. For assistance in determining the process for a specific purpose, contact your RSP Grants Specialist.
The Principal Investigator (PI) is responsible to verify that all PCard purchases have been appropriately coded and approved prior to the purchase as required under OMB Circular A-21 for purchasing using grant funds. It is especially important for the PI to monitor PCard purchase approvals during the first 30 days after the end of the project to ensure that encumbrances are posted promptly in order to generate the final expenditure reports. See the PCard Reference Guide web page for more information.
Sponsored Research Exemption
The University Policy PR-01.02-08/11 for Sponsored Research Exemption (PDF) gives RSP the authority to exempt from the bidding procedure any purchase made with research funds which would provide for the more efficient and expeditious management of a research project. The exemption is authorized by the Florida Statute 1004.22. The PI should adhere to the procedures in the Request for Sponsored Research Purchasing Exemption. The form provides the details on the rationale and conditions for approval of an exemption to the university's usual purchasing policy for goods and services dictated by the requirements of a sponsored research project.
Conditions that support a Sponsored Research Purchasing Exemption include
- A certain vendor is specified by the prime contractor or granting agency in accordance with the provisions of the prime contract or grant award.
- The purchase of specific goods or services from a certain vendor can be demonstrated to be more efficient or expeditious based on compatibility, availability, or the current capabilities of the PI and staff.
- The purchase of specific goods or services from a certain vendor can be demonstrated to be necessary to meet time requirements of the prime contract or grant award.
- The purchase of specific goods or services from a certain vendor can be demonstrated to be mandated by scientific or technical requirements.
- The purchase of specific goods or services from a certain vendor can be demonstrated to be at a cost below industry norms.
- The prime contract, grant award, or subcontract contains a confidentiality clause requiring the research materials to be exempt from public scrutiny, pursuant to Florida Statute 1004.22.
- For non-State of Florida personnel, the allowances for travel expenses in accordance with the provisions of the prime contract, grant award or the subcontractor's written policy are greater than the allowances provided by the State of Florida (a copy of the documentation shall be made a permanent part of the supporting material contained in the RSP contract file).
- The level of detail and documentation for reporting and payment required by the prime contractor or granting agency in the provisions of the prime contract or grant award (or approved in writing by the sponsor) is less than that required by the State of Florida.
- The subcontractor or vendor requests an advance payment which is necessary to fund extensive start-up costs, receive discounts or cost savings, or create adequate cash flow in order to provide required goods or services. The university shall retain the documentation justifying advance payments in the RSP contract file and implement appropriate procedures to ensure that goods and services are received as required.
- Other conditions which can be demonstrated to meet the statutory criteria necessary for the efficient or expeditious prosecution of a research project. The specific condition must be fully explained in the exemption certification.
The Request for Sponsored Research Purchasing Exemption requires the endorsement of the chair/director, dean/vice-president, and the Associate Vice President for Research. Upon receipt of the request, RSP will prepare the recommendation for consideration by the University General Counsel and the president. All approvals must be completed prior to the issuance of any purchase order, contract, or commitment. For additional information, please contact your RSP Grants Specialist.
Records Management & Retention
|UWF Records Management|
Grantees are required to keep intact and accessible all financial and programmatic records, supporting documents, statistical records and other records pertinent to an award. The records retention and custodial requirements extend not only to the records of the grantee, but to those of its sub-grantees, contractors and subcontractors. Records must be retained for a period of no less than five years or longer as specified in each agreement.
A grantee's property records for nonexpendable personal property (e.g., equipment) acquired under the grant must be retained for three years after the final disposition of the property. Records should include the following:
- Description of property.
- Manufacturers' serial number, model number, Federal Stock Number, National Stock Number, or other identification number.
- Source of the property, including grant or agreement number.
- Property title holder.
- Acquisition date and cost.
- Percentage (at the end of the budget year) of federal participation in the project or program for which the property was acquired.
- Location, use, condition and the date the information was reported.
- Unit acquisition cost.
- Ultimate disposition data, including date of disposal, sales price or method used to determine fair market value where a grantee compensates the agency for its share.
- Take a physical inventory at least every year with the results reconciled with property records. The inventory should verify the existence, current use and continued need for the property.
- Establish a control system of adequate safeguards and maintenance to prevent loss, damage, or theft.
- Maintain property in good condition.
- Use selling procedures that provide for competition that will result in the highest possible return.
It is the responsibility of the Principal Investigator (PI) to notify UWF Property of any need to transfer or relocate property, check out property for off-campus use of 1-10 days or in excess of 10 days, to request survey of property, or to report missing/stolen property. Forms for property actions are available at the Financial Services web site and must be routed through RSP for signature before final routing to Property.
The federal government sets forth the basic grantee financial management standards in OMB Circulars A-110 (2 CFR Part 215) (PDF) and A-21 (2CFR Part 220) which apply to all grant programs and provides for
- accurate, current, and complete disclosure of the financial results of each grant program;
- accounting records which identify the source and use of grant funds;
- account control for all grant funds, property, and other assets.
At UWF, these requirements are met through a uniform accounting system that provides the basic controls as well as accounting reports that will assist faculty and their staff in managing contracts and grants. The university accounting system is under the jurisdiction of Financial Services and the Vice President\Chief Financial Officer for Business, Finance & Facilities. Questions or inquiries concerning accounting should be addressed to RSP at 850-473-7111.
Audits & Access to Records
|OMB Circular A-133 (29 CFR Part 99) (PDF)
OMB Circular A-21 (2 CFR, Part 220) (PDF)
Internal and external constituencies (auditors, program or grants officers, sponsor's designees for administration and oversight, etc.) often conduct reviews of different levels of effort to assess or monitor program effectiveness. These reviews may be informal site visits of a technical or program officer or may be a full request for a self-study prior to a site visit or a formal audit. In any circumstances of a review of the administration and management of sponsored research projects, programs, or related activities, RSP is charged to coordinate and assist the PI or department or institute/center in preparing for and responding to such review requests. In cases of external reviewers, UWF IAMC must also be apprised of the review and will determine if staff from this department should be involved. All responses for such external reviews should be approved by RSP and the IAMC offices before being communicated to the external entity.
Compliance with guidelines, rules, and procedures in one project often affect the status of the institution at large. Therefore, such reviews are extremely important in demonstrating the university's overall eligibility for funding and participation in such programs. A coordinated response to any such request is critical. PIs and other designated staff have the responsibility to work with the two offices to provide appropriate response and information as needed.
This section provides the Principal Investigator (PI), departmental support personnel, and administrative officers with guidelines for external review and internal or external monitoring in regard to sponsored research (or related) projects. As the office charged with oversight of grant projects and OMB compliance, RSP is the internal authority on program or budget compliance. Therefore, coordination with RSP staff is critical for any visits or inquiries regarding projects.
All records are subject to audit and any authorized representative of the grantor (prime agency or first-tier recipient), the state or the university shall have right of access to any books, documents, papers or other records of the grantee which are pertinent to the contract or grant. The right of access shall not be limited to the required retention period but shall last as long as the records are retained.
UWF falls under OMB Circular A-133 regarding federal audit requirements on grants, contracts and other agreements. RSP should be promptly informed when a sponsor announces its intent to conduct a contract or grant audit. Staff from the appropriate fiscal office will accompany the auditor and be available during the visit to help interpret and understand the requests of the audit. Audit visits should be prepared for as soon as notification is received in order to assure maximum coordination of staff time and availability of records.
The following is a non-exclusive list of the types of reviews, audits, and monitoring which internal/external authorized personnel may request of a PI, budget manager or administrative unit:
- Audits -- UWF Internal Auditing and Management Consulting Department (IAMC), Florida Auditor General, Office of Management and Budgets (OMB), or any sponsor agency or authorized representative on any aspect of project;
- Pre-contract or contract negotiations and discussions;
- Reviews (program, participant, sponsor or compliance);
- Monitoring visits (program, progress, sponsor);
- Site visits (program, progress, sponsor);
- Progress or interim visits/reviews; and
- Organized inquiries regarding the functions or activities related to a project, program, or institute/center, which is sponsored by or related to a sponsored project.
Audits, reviews and monitoring may take a number of different forms including but not limited to
- Formal procedures with entrance and exit conferences.
- Desktop reviews (usually consisting of web site access and reviews)
- Paper only (requests for interim reports, financial records or supporting documentation on financial reports submitted)
- Verbal (phone, fax, or e-mail requests for data)
- In person (actual schedule of meetings with or visits by internal or external persons to review some aspect of project performance or management).
In all cases, the notified party has certain responsibilities to coordinate and cooperate with the relevant campus offices involved in the review. Some useful information on audits, investigations, and reviews is available from the UWF IAMC internal web site.
- Notify RSP and/or IAMC staff of any contact from external personnel requesting review or monitoring of a sponsored research project or an institute/center.
- Cooperate with RSP coordinator in reviewing and preparing for the upcoming review.
- Forward all pre- and post-visit correspondence to appropriate parties.
- Adjust future project management and oversight to address any findings or determinations.
- Assist PI/Director in preparing required materials and documents for upcoming review.
- Coordinate financial and related reports needed or assist in retrieval of additional supplemental documentation.
- Participate in all meetings related to review (before, during and after).
- Assist PI/Director in preparing response to any comments, findings or determination.
- Follow up to address any deficiencies in university policy and or procedures as part of on-going quality assurance and compliance issues on future activities.
- Participate in and/or coordinate all contract negotiations or discussions of terms and conditions with external sponsors.
Most sponsored projects require a number of reports during the life of the project. The Principal Investigator (PI) should be prepared to submit a final technical report at the very least. The importance of the submission of such a report on a timely basis cannot be overstated. The sponsor expects and deserves to be informed of results. Negligence by the PI may substantially impact his/her and the university's ability to receive future support from the sponsor and may also result in a loss of payment to the university for costs incurred. Such losses could become a liability chargeable to the investigator, department and college.
In addition to the technical report(s), other reports may be required:
RSP Grants Specialist
RSP Financial Manager
- equipment accountability
- fiscal data
- invoice submissions
Time & Effort Reporting
Under federal regulations, the University is obligated to provide detailed records of time and effort spent by faculty and staff on activities such as instruction, research, extension, public service, administration, and so forth.
Documentation of time and effort activity is required on all contracts and grants regardless of the source of funding and on all other activities that would have an impact on F&A costs. The University must be ready to provide sufficient detail concerning these activities to allow a reviewer to determine whether the work performed benefited sponsored projects. Faculty are reminded to take these reporting duties very seriously. Refer to the UWF Combined Activity/Effort Reporting System (CAERS) User Manual (PDF) for more information.
Total UWF Effort
The federal government acknowledges that practices vary among institutions and within institutions as to the activity constituting a full workload. Accordingly, institutions are permitted to express effort in terms of a percentage distribution of total institutional activities.
UWF’s CAERS is intended to report 100% of an individual’s university activity. University activity includes teaching, research, public service, administration and other university-related activities. It also includes activities performed by UWF personnel related to community service, service to the university and/or service to his/her department. RSP’s staff offers periodic training to individuals/groups and will provide assistance upon request.
Only specific employee activities have to be certified on an effort report under OMB Circular A-21 regulations. Activities that are always certifiable are the direct activities of Sponsored Research, Sponsored Instruction, Other Sponsored Activities, and associated cost sharing. When an individual has a pay distribution during the semester from a UWF fund classified as one of these certifiable activities, then CAERS will be required for that individual. CAERS will include 100% of the individual’s effort related to the base salary for which UWF compensates the individual. For example, an employee may be employed for .5 FTE or half time, but the .5 represents 100% of the individual's university related appointment. Therefore 100% of the contracted effort is allocated to the salary source.
Effort Report (CAERS)
UWF's effort reporting is done on a semesterly "after-the-fact" basis. This means the CAERS report is completed in the semester following the activity. The individual will receive email notification when the system is open for CAERS submission. The CAERS reports are to be completed within 60 days of the end of the prior semester.
Changes in Effort
A Personnel Action Sheet should be submitted to officially change the payroll account distribution of an employee when that individual's effort changes. This will record the account distribution change on the Effort Report for future pay periods.
Occasionally, corrections must be made to a previously certified effort report. When retroactive payroll changes are made to a previously filed term effort report (CAERS), each effort report must be re-certified and an explanation of why the change was made must be provided.
Individuals Subject to the Federal Executive Level Salary Cap
The legislative mandated provision on some federal programs (such as NIH) imposing a cap on reimbursement of salaries creates a special problem in completing effort reports at UWF for highly compensated faculty and staff. By law, these federal agencies may not reimburse salaries under awards at an annual rate that exceeds the cap. This requires UWF to create a special Effort Report for those individuals that are compensated from these awards. These Effort Reports have to reflect the NIH salary cap base in effect for each award. The difference in the amount charged to the UWF account and the federal salary cap base is considered cost sharing for UWF. Once the effort report is certified, entries will be made to record this cost sharing.
RSP Seed Accounts
RSP sets up “seed” funds for new Principal Investigators (PIs) when a grant/contract has been awarded. The purpose of these funds is to collect residuals from terminated fixed price/rate contracts and annual Facilities and Administrative (F&A) distributions. According to Florida Statue 1004.22(5), seed funds are to be used to support research or research-related activities that are allowed from university funds. The monies in the funds are distributed as described in the UWF F&A Return Distribution Policy.
Use and Restrictions of Seed Funds
The following is a list of the common uses for these funds:
- Acquiring research program support supplies, equipment, or services which are normally allowed under the University’s procurement policies.
- Support of travel related to research, scholarship, or professional development of individual and/or any assistants or students.
- Professional licenses, certifications or memberships.
- Employment of research support personnel such as OPS staff or students, consultants, or other professionals with special skills to assist in advancing research programs.
- Scholarship/tuition reimbursement for graduate research assistants.
- Buy-out of an individual’s normally assigned activities to pursue an approved research project by charging salary and fringe related to appointment for the equivalent percentage of faculty contact hours during either a regular or summer appointment period (Refer to Use of SEED Accounts for Salary (PDF) 2/4/91 Provost memo.)
Seed funds MAY NOT be used for the following:
- Overload or extra-state compensation payments.
- A salary supplement or increase over the individual’s established university base rate.
- Costs associated with credit instruction or administrative support.
For further reference, please check the Academic Affairs Faculty Handbook (links updated) 1/8/14.
Other Prohibited Expenditures
Any purchase or service on the State Bureau of Auditing Reference Guide for State Expenditures (PDF) for which expenditures are prohibited from state funds such as a) promotional gifts (i.e., T-shirts), b) personal compensation items, c) appliances, d) commemorative plaques or items such as e) flowers, f) greeting cards, g) decorative items, h) food, i) beverages, j) meals other than authorized travel, and k) entertainment or lobbying. See Procurement and Contracts' Expenditure Restrictions and Guidelines for further guidance.
The Principal Investigator (PI) is primarily responsible for the technical conduct and management of the project to assure that contractual and regulatory conditions are met, and to make certain that the program stays within its budget. Costs associated with a project are expected to be charged directly to the project. The PI, department chair, and college dean are all expected to exercise responsible judgment in the administration of the project, particularly with regard to the terms of the agreement and university policies and procedures. Financial liabilities which result from failure to comply with the grant or contract become the responsibility of the PI, department and college.
- is responsible for project implementation, assembling the necessary staff, properly expending the funds, and conducting the project as described in the proposal and agreed to by means of the award notification.
- must direct the work so that it will be completed within the performance period and with the funds authorized; otherwise, a request for supplemental funds or a no-cost time extension must be initiated. Researchers are expected to familiarize themselves thoroughly with the regulations applicable to their specific project/agency.
- may authorize changes when they are in compliance with the agency's cost principles, as well as the State of Florida's fiscal regulations, and if the goods or services are directly related to the sponsored project. Salaries and wages may be authorized by the investigator only if they are in accordance with OMB Circular A-21.
- has first line responsibility for managing expenditures within the fiscal regulations and amounts specified by the sponsor. The PI must carefully analyze the Information Navigator report Grant Inception-To-Date w/ FUND (RSP000008) report to see that all items presented are correct and that appropriate funds (cash and budget authority) are available. The PI also has the responsibility of initiating or coordinating appropriate adjustments as each situation dictates. It is suggested that this analysis take place no less than monthly in order to provide for timely action if needed.
- is responsible for any exempt purchases (see Expenditure Restrictions & Guidelines) purchased in conjunction with a grant and must provide written documentation stating the purpose, list of attendees, and authorized approval.
- is responsible for ensuring that the cost sharing commitment is met on a grant or contract and to provide RSP the documentation necessary to track cost sharing commitments.
- must approve all expenditures such as, but not limited to, personnel actions, purchases, travel, transfers or recharges of expenditures, CAERS, and distribution of funds to other university accounts.
Changes to your grant
Institutional Approval of Requests to Modify Budget
OMB Circular A-21 and OMB Circular A-110 also provides for federal agencies to allow for rebudgeting of funds under certain conditions without agency approval. These actions may be done internally with review and concurrence of RSP unless prohibited by specific agency or award guidelines which prohibit it. Some conditions which prohibit internal approval and require agency authorization include
- Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval).
- Change in a key person specified in the application or award document.
- The absence for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or Principal Investigator (PI).
- The need for additional federal funding.
- The transfer of amounts budgeted for indirect costs to absorb increases in direct costs, or vice versa, if approval is required by the federal awarding agency.
Prior Approval for Post-Award Changes
When researchers consider rebudgeting or other post-award changes and are uncertain about the allowability of such changes—particularly when such items are not mentioned in the agency or award regulations, cost principles or other policy documents—they are strongly encouraged to consult in advance with the designated RSP Grants & Contracts Business Manager and Grants Specialist. Some of the most common post-award changes that require agency prior approval are
- Changes in the scope or objectives of the grant-supported activities.
- Significant change in responsibilities or replacement of the approved project director (PI), or other persons expressly identified as key personnel by the agency in the Notice of Grant Award or by the grantee in the application.
- Continuation of the project during any continuous period of more than 3 months without the active direction of an approved project director or PI.
- Undertaking any activities or expenditures disapproved or restricted as a condition of the award, including restrictions imposed by standard provisions such as cost principles.
- A request for additional federal funds, excluding those situations where the need for additional funding results from an increase in the base upon which indirect costs are calculated (due to otherwise allowable rebudgeting actions, such as rebudgeting into the personnel category whereby allocations of indirect costs increase).
- The transfer of amounts previously awarded for trainee costs (stipends, tuition, and fees) to other categories of expense. rebudgeting within the category of trainee costs or into the trainee costs category is allowable without the awarding office's prior approval.
For more information, please contact the RSP Associate Director at 850-473-7111, or the appropriate fiscal office.
When a major budget change (as determine by the grantor) is necessary, a letter from the Associate Vice President (AVP) for Research should go to the agency requesting necessary changes in the form of a contract or award amendment. The amendment will reflect the necessity of amendments or internal budget changes (projects under the Federal Demonstration Partnership (FDP) need only the approval of the AVP provided no change is made to items shown in Prior Approval above). When an agency approval for an amendment is required, it usually takes the same period of time as request for a no-cost extension or program change. A 30-60 day period should be planned for the agency response PRIOR to executing the amendment in university accounting records or in committing or authorizing expenditure of funds.
When a contract or award allows for internal budget changes, a budget amendment/transfer form should be forwarded to RSP with the proper signatures and justification for transfer for approval and processing.
Reallocations within awarded budgets are usually possible, but the sponsoring agencies have different restrictions on deviations from the approved budget. The National Institutes of Health (NIH) and the National Science Foundation (NSF) are among the federal agencies that have granted authority to the University for self-management of certain budget deviations. Requests for budgetary reallocations require the use of the University Budget Transfer form. Principal Investigators (PIs) uncertain of the budgetary restrictions imposed by any particular sponsor should first consult the award document and any of its inclusions by reference. The PI may also consult the Award Summary and Budget Form issued by RSP for that account, or they should consult their department business offices. If Budget Amendment forms are submitted that are deemed to require agency approval, they will be returned to the PI with supporting documentation or a request for agency authorization will be coordinated with the PI by the RSP Grants Specialist. When an agency approval for an amendment is required, it usually takes the same period of time as request for a no-cost extension or program change. A 30-60 day period should be planned for the agency response PRIOR to executing the amendment in university accounting records or in committing or authorizing expenditure of funds.